EMR response to criticism in full

European Metals Recycling (EMR) responds to criticism over its cheque cashing facilities.

EMR have developed a range of payment methods in response to the LASPO Act and the introduction of the cash ban from the 3rd of December.

Our objective has been to offer convenient, cost effective and above all legally compliant methods of payment.

To achieve this we have introduced a range of payment methods including instant bank transfer, pre-paid card and cheque payment.

With all of these services we have negotiated hard with the service providers to keep costs to a minimum for our suppliers.

In the case of cheque payment, suppliers can either bank the cheque in their own account, or use a cheque cashing service. We have negotiated what we believe are the lowest costs on the high street with two leading cheque cashers. In addition we have teamed up with a leading UK PLC to provide an on-site cheque cashing service, offering both convenience and low cost.

Where we are providing an on-site service the key factor is that we are not acting in our own capacity but as an Agent of the cheque cashing company, and as such we are acting under their Money Service Business (MSB) registration. All relevant members of staff have been trained and third party assessed as competent in this regard and all our sites have been registered with HMRC as agents under the relevant Money Service Business Regulations.

Before embarking on this course of action we took great care to satisfy ourselves that it was compliant with both the letter and the spirit of the law, including discussions with senior police officers and HMRC Home Office Guidance on the cash ban legislation clearly states ‘The over-riding requirement is for transactions to have traceability and to provide an effective audit trail.’

All our methods of payment meet this test, as we have adopted appropriate standards of identity checking – what is referred to as KYC, or ‘know your customer’ and have built robust systems which clearly demonstrate our compliance.

Perhaps given the nature and scale of the change facing our industry and the speed at which it has had to be accommodated there is an understandable lack of comprehension and fair degree of angst amongst many in the trade – but it is misdirected. The methods of payment we have adopted and the systems and controls we have developed, are fully compliant with both the letter and the spirit of the legislation.

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